SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part 51

- App. V)

SIP Submitted by: John Quigley, Secretary, Pennsylvania Department of Environmental Protection (PADEP)

Date Submitted: Letter dated September 30, 2015, received October 1, 2015 Subject: 2011 Base Year Inventory for the following marginal areas for the 2008 National Ambient Air Quality

Standards: Allentown

- Bethlehem

- Easton, Lancaster, Pennsylvania portion of the Philadelphia

Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, and Reading

Completeness Review Completed by: Maria A. Pino Date Completed: 9 October 2015

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal signed, stamped, and dated letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. If electing to submit a paper submission with a copy in electronic version, the submittal letter must verify that th e electronic copy provided is an exact duplicate of the paper

submission. 1. Letter t o Shawn M. Garvin, Regional Administrator, EPA Region III

., dated September 30, 2015 , from PADEP Secretary Quigley, received October 1, 2015

.

2. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement in final form. That evidence shall include the date of adoption or final issuance as well as the

effective date of the plan, if different from the adoption/issuance date. 2. N/A

– Not a plan or regulation, sp not “adopted.” Final emissions inventory report, dated September 2015, “State Implementation Plan Revision: 2011 Base Year Inventory for Pennsylvania Portion of Fiv e 2008 Ozone Nonattainment Areas:

Allentown

- Bethlehem

- Easton, Lancaster, Philadelphia

Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, Reading” (September 2015 SIP Revision Submittal). 3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 3. The emission inventories are not “plans or regulations.”

However, s ection 5 of the Air Pollution Control Act (35 P. S. § 4005) subsection (a)(1) grants Pennsylvania’s Environmental Quality Board the autho rity to adopt rules and regulations for the prevention, control, reduction and abatement of air pollution in this Commonwealth, and subsection (a)(8) grants the Board the authority to adopt rules and regulations designed to implement the Clean Air Act (CAA ) (42 U.S.C.A. §§ 7401

— 7671q).EPA REQUIREMENT STATE SUBMITTAL (X)

4. A copy of actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication of the changes made (such as redline/strikethrough) to the existing approved plan, where applicable. The submission shall include a copy of the official State regulation/document signed, stamped, dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date of any regulation/document contained in the submission shall, whenever possi ble, be indicated in the regulation/ document

itself ; otherwise the State should include a letter signed, stamped, and dated by the appropriate State official indicating the effective date. If the regulation/document provided by the State for approval and incorporation by reference into the plan is a copy of an existing publication, the State submission should, whenever possible, include a copy of the publication cover page and table of contents

. 4. State Implementation Plan Revision: 2011 Base Year

Invent ory for Pennsylvania Portion of Five 2008 Ozone

Nonattainment Areas: Allentown

- Bethlehem

- Easton, Lancaster, Philadelphia

- Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, and Reading, dated September 2015

5. Evidence that the State followed all of the proce dural requirements of the State’ s laws and constitution in conducting and completing the adoption/issuance of the plan. 5. Statement in September 30, 2015 submittal letter from PADEP Secretary Quigley. Copies of public notice in the Pennsylvania Bul letin and newspapers.

6. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date of publication of such notice. 6. Notices in the Pennsylvania Bulletin (45 Pa.B. 4985, 8/22/2015), Allentown Morning Call (8/19/2015), Bucks County

Courier Times (8/19/2015), Delaware County Daily Times (8/19/2015), Harrisburg Patriot News (8/18/2015), Lancaster New Era (8/20/2015), Pittsburgh Post

- Gazette (8/18/2015), and Reading Eagle (8/19/2015). 7. Certification that public hearings were held in accordance with the information provided in the public

notice and the State’ s laws and constitution, if applicable. 7. N/A

– No public hearing was requested , as stated in the September 30, 2015 submittal letter . Public notice cited in #6, above, included opportunity to request a public hearing.

8. Compilation o f public comments and the State’ s response thereto. 8. N/A

– No public comments were received , as stated in the September 30, 2015 submittal letter.Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. VOCs, NOx, and CO emissions under the 2008 ozone NAAQS , as stated in the Introduction and Overview section of

the September 2015 SIP Revision S ubmittal.

2. Identification of the locations of affected sources including the EPA attainment/nonattainment designation of the locations

and the status of the attainment plan for the affected area(s). 2. Marginal nonattainment areas under the 2008 ozone NAAQS, the Allentown

- Bethlehem

- Easton, Lancaster, Philadelphia

- Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, and Reading Areas , and described in the Intro duction

and Overview section of the September 2015 SIP Revision

Submittal

3. Quantification of the changes in plan allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result

of the revision. 3. N/A. This is the 2011 Base Year In ventory, representing VOCs, NOx, and CO emissions in the Allentown

- Bethlehem

Easton, Lancaster, Philadelphia

- Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, and Reading Areas in calendar year 2011, as described in the Summary of the Base Year Emissions Inventory s ection of the September 2015 SIP Revision

Submittal

.

4. The State’s demonstration that the national ambient air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemente d. 4. N/A. This is the 2011 Base Year Inventory, representing VOCs, NOx, and CO emissions in the Allentown

- Bethlehem

Easton, Lancaster, Philadelphia

- Wilmington

- Atlantic City, Pittsburgh

- Beaver Valley, and Reading Areas in calendar year 2011, as described in the Summary of the Base Year Emissions Inventory section of the September 2015 SIP Revision

Submittal. 5. Modeling information required to support the proposed revision, including input data, output data, models used, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. 5. Files with technical information & data supportin g the emissions inventory are contained in CDs accompanying the

submittal.

6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. 6. N/AEPA REQUIREMENT STATE SUBMITTAL (X)

7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. 7. N/A

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8. N/A

9. Special economic and technological justifications required by any applicable EPA policies. (If a policy is not appropriate, explain why.) 9. N/A

10. A Section 107 request must be accompanied by a maintenance plan demonstrating maintenance to the relevant NAAQS for at least 10 years after redesignation. 10. N/A